France’s EPR Packaging Requirements

Extended Producer Responsibility (EPR) regulations are designed to reduce waste and encourage recycling. Starting January 1, 2022, France’s revised EPR laws for packaging affect us and our sellers.

The Ministry for Ecological Transition (MoET) provides a general overview of EPR requirements in French. France requires “producers” to mitigate the environmental impact of their products and packaging. Producers are not just manufacturers. You are considered a producer if you ship items to customers in France.

These regulations require “producers” to register with a Producer Responsibility Organization (PRO).

If you need assistance with EPR, there is a list of authorized third-party companies offering support services.

How to comply with France’s EPR Requirements

Follow these steps to be compliant with EPR Regulations in France.

Step 1: Register with a PRO and obtain an EPR Registration number for France

In France, the following PROs handle packaging.

Citeo – general information / registration (Available in French)
Léko – general information / registration (Available in French)

Register with one of them and obtain an EPR Registration number for France (also known as Unique Identification Number or UIN).

The UIN starts with FR and follows this format: FR123456_78ZZZZ

While registering, ensure that the information submitted to the PRO, including your VAT ID/Tax ID and business name matches the information on file with us.

Step 2: Submit your UIN to us

Provide your UIN to us by following these steps:

  1. Sign in to your seller account.
  2. Go to the Compliance Items section of your Members Menu and click Extended producer responsibility.
  3. Click Add inthe France row.
  4. Enter your UIN into the Registration number field and click Add.

Step 3: Report packaging volumes and pay eco-fees

Submit reports and pay eco-fees to your PRO on a regular basis.
 

What happens if you don’t comply with France’s EPR Requirements

If you don’t provide us with a UIN in 2022, we will pay the corresponding eco-fees to the qualified PRO on your behalf for sales made from January 2022. We won’t recover any eco-fees paid on your behalf for 2022.

If you don’t provide us with a UIN by the end of 2023, we will pay the corresponding eco-fees to the qualified PRO on your behalf for all sales made from January 2023, and recover those eco-fees from you annually.

If you register with a PRO but don’t provide us with a UIN, this may result in double-payment of eco-fees, to the PRO and to us. To avoid double-paying eco-fees, we encourage you to register with a PRO and provide us with their UIN.

PROs for packaging offer lower eco-fees if you use recycled or eco-friendly material in your packaging. You can only benefit from lower eco-fees if you register with a qualified PRO, make declarations and pay the eco-fees yourself. If we pay eco-fees on your behalf, you may not benefit from lower eco-fees. Please refer to a PRO’s pricing schedule for more details about how eco-fees are calculated.

Frequently Asked Questions

How do I know if I am a “producer” in France?

According to the legislation, you are considered a producer if you ship items to customers in France.

Where can I learn more about France’s EPR regulations?
The following websites offer general information in French:

Contact your PRO with questions about registration, reporting and payment of eco-fees.

How do I determine the total order value of sales to a specific country?

  1. Sign in to your seller account.
  2. Go to the My Payments section of the Members Menu and click Statements & Reporting.
  3. Go to the Downloads tab.
  4. Select the Custom Date Range option and enter the Start Date and End Date.
  5. Click Download. The report is provided in .CSV file format and you can open it using Microsoft Excel.
  6. Filter your sales by Order Country (Column H). The Order Country Column of the report allows you to filter sales by buyer country. The Order Country is indicated in 3 letter ISO country codes. Use FRA for France and DEU for Germany.
    • To calculate the total value of your sales for the country, add the values in Column N (total price).
    • To calculate the total number of orders, count the number of rows (and exclude the Header row).

I don’t want to register with a PRO. I want to opt out of selling to customers in France. What do I do?
If you want to opt out of selling to customers in France, please inform us so that we can add you to the opt out list.
 

Frequently Asked Questions – Registration & Reporting

What happens if I don’t register with a PRO?
We will pay eco-fees to a qualified PRO on your behalf for all sales made from January 2022. We won’t recover any eco-fees paid on your behalf for 2022. If you don’t register with a PRO and don’t provide us with your UIN in 2023, we will pay eco-fees to the qualified PRO on your behalf and recover those eco-fees from you annually.

What happens if I register with a PRO but I don’t submit my UIN to AbeBooks?
If you register with a PRO, and don’t submit your UIN to us, we’ll continue paying eco-fees on your behalf and recover those eco-fees from you annually. Since you are registered, your PRO will collect eco-fees from you directly as well. This means you could end up paying eco-fees twice, to a PRO and to us.

To avoid paying eco-fees twice, we encourage all sellers to be EPR compliant by registering with a PRO and providing us with their UIN.

If I don’t register with a PRO, can I still continue selling into France?
If you don’t register with a PRO and if you don’t provide us with the valid UIN, we will by default pay eco-fees to the qualified PROs on your behalf for sales made from January 2022. We will not recover any eco-fees paid on your behalf for 2022. If you don’t register with a PRO in 2023, we will pay eco-fees to the qualified PRO on your behalf and recover the eco-fees from you annually.

How do I submit EPR reports for France?
You submit EPR reports for France through SYDEREP, an online portal maintained by France’s Agency for Ecological Transition (Ademe).

Can I appoint an authorized representative to fulfill obligations on my behalf?

Yes, you can appoint an authorized representative to fulfill some obligations on your behalf.
 

Frequently Asked Questions – EPR Fees

How much does it cost to register with and report to a PRO in France?

While it is free to register with PROs for packaging, including Citeo and Leko, you will be required to pay reporting fees on a regular basis. Please refer to a PRO’s pricing schedule to learn more about how fees are calculated.

I use recycled materials in my packaging. Do I still need to pay eco-fees?
If you register with a PRO directly, and you use eco-friendly or recycled packaging, you may benefit from lower eco-fees. Please refer to a PRO’s pricing schedule to learn more about how eco-fees are calculated.

Does AbeBooks charge a service fee for paying on my behalf if I don’t provide a valid UIN?
No, we’re not charging a fee for this service.

Will PROs request retroactive payments when I register with them?
Some PROs may charge you eco-fees for products put in France in previous years. The period covered by retroactive payments varies by eco-organization but can cover up to three previous years. Please refer to the PROs for more details.

Frequently Asked Questions – UIN Validation

How will you validate my UIN?
We’ll use your company name and/or SIREN/SIRET number to validate your UIN in the French government’s SYDEREP portal. Please make sure that the data on SYDEREP matches what you’ve provided to us.

If your EPR number fails validation, we’ll notify you via an Action Required message in your seller account. You can also see the status of your EPR number at any time on the EPR page in your seller account.

What do I need to do if my UIN is invalid?
After we validate your number against the French government’s SYDEREP portal, we’ll update the status next to your number to Pending or Valid or „Rejected„. If your EPR number is rejected, the message will also display the rejection reason.

  • If the status is Valid, no further action is required from you.
  • If the status is Rejected, please refer to the reason provided and take appropriate action.


I have registered with a PRO to get my UIN, but have not received it yet. What should I do?
Keep checking the portal of your PRO for your UIN. Once you receive the UIN, provide it to us as soon as possible.
 

Frequently Asked Questions – Payments on my behalf

When will eco-fees be paid on my behalf to a qualified PRO?
We pay eco-fees according to the PRO’s reporting cycle. Since PROs for packaging have annual reporting cycles, we pay eco-fees annually.

Will you pay eco-fees on my behalf after receiving my UIN?
We will only pay eco-fees on your behalf to a qualified PRO for reporting cycles in which we don’t have a valid UIN on file for you. Since PROs for packaging have annual reporting cycles, if you provide us with your UIN mid-year, we’ll stop paying eco-fees on your behalf from that year onwards. This means that if you provide us with a UIN any time in 2023, we will not recoup eco-fees from you for sales made from January 2023. Once you’re registered with a PRO, they collect eco-fees from you directly.

Will you pay eco-fees on my behalf for sales made on other online stores than AbeBooks?
We will only pay eco-fees on your behalf for sales on all our domains, including abebooks.com, abebooks.co.uk, abebooks.fr, abebooks.de, abebooks.it, iberlibro.com and zvab.com.

Will you pay eco-fees on my behalf for sales shipped out of France?
No. According to EPR requirements, eco-fees are only paid for sales made to customers with a shipping address in France. This also includes French overseas territories.

How long will you continue paying eco-fees on my behalf?
We’ll continue paying eco-fees on your behalf (and recouping those fees from you) every year as long as you don’t provide us with a UIN. This will help you continue selling with us. Since PROs for packaging have annual reporting periods, if you provide us with a UIN number mid-year, you’re considered compliant from that year onwards. Once you’ve registered with a PRO, they will collect eco-fees from you directly.